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{ <, . . Rather than addressing the proposed action, the BO discusses a wide range of biological and meteorological topics that have nothing to do with the proposed action. The BO needs to focus solely on a factual analysis of the biological impacts of the proposed action. There is no place in what should be solely a scientific and data-based evaluation for the innuendo and personal opinion espoused throughout the BO. SWCD has supported twelve years of SJRIP data collection efforts at a cost of tens of millions of dollars just so that USFWLS and other biologists can make data-based evaluations. The BO disregards this twelve years of effort and the large sums spent on research. Throughout the BO, USFWLS describes, as a baseline condition, idealized water flow and habitat conditions that probably never existed pre-Navajo Dam. This idealized baseline is totally inappropriate because it does not address the proposed action., The period which should be compared to that of the proposed action is the post-Navajo Dam period from 1965 to 1991. The BO is based on the 20 year old unproven assumption that more and more water is needed to recover the endangered species. After twelve years of the operation of Navajo Reservoir to mimic a natural hydrograph, as defined by the SJRIP Biology Conunittee, the data indicate that stocking is the critical measure for recovery, not flows. Both a recent analysis of mimicked flows on the Yampa River by the Colorado Division of Wildlife and an analysis of the SJRIP Flow Reconunendations using The Nature Conservancy habitat alteration model show that more flow is not the answer. The timing and type of flows are more important. SWCD requests that USFWLS significantly modify the BO to address the proposed action and to support its conclusions solely through the data developed over the past twelve years of SJRIP research, rather than through unsupported philosophies. Conunents on Reasonable and Prudent Measures Measure I. No conunent. Measure 2. USFWLS seems to have decided that the temperature of the water released from Navajo Reservoir is a critical component of the recovery of the endangered fish in the San Juan River without any review of the available data and without any scientific evaluation to support this premise. USFWLS must soften this position because it is unsupported by the data. USBR has developed a model to study the impact on San Juan River water temperatures of the release of water of varying temperatures from Navajo Reservoir. The model was presented at the SJRIP Hydrology Conunittee meeting in January 2004, at which a USFWLS representative was present. The preliminary runs of the model show that even releasing the wannest possible water from Navajo Reservoir during the endangered fish spawning period, on the descending limb of the spring runoff hydro graph, will not measurably increase the temperature of the 01270